First, direct salaries Second,

Harrison, On behalf of the Council on Governmental Relations (COGR) and its 219 member institutions and the Association of Independent Research Institutes (AIRI) and its 82 member institutions, we seek your assistance to withdraw any consideration of a policy change that would apply the Executive Level II salary limitation to indirect salaries paid with institutional funds. [...] First, we believe a policy change would be inappropriate for the following reasons: 1) The established 30-year policy on the application of the Executive Level II salary limitation for HHS/NIH funded research is clear: it is applicable only to the direct salaries of individuals paid from federal funds. [...] This is reiterated in the recent NIH Notice, NOT-OD- 24-057: The Consolidated Appropriations Act, 2023 restricts the amount of direct salary to Executive Level II of the Federal Executive pay scale. [...] 2) NOT-OD-24-057 is consistent with longstanding statutory language in the annual HHS appropriations bills: None of the funds appropriated in this title shall be used to pay the salary of an individual through a grant or extramural mechanism, at a rate in excess of Executive Level II. [...] 3) The unintended consequences of a policy change would be significant, and include: a) New administrative burden for both grantees and for CAS in order to develop and negotiate F&A cost rates.